| Status | Enacted Law |
| Law | On August 20, 2025, the Slovakian Government issued a draft law to implement the OECD June 2024 and January 2025 OECD Administrative Guidance. This was approved by Parliament on October 21, 2025. On June 16, 2025, Slovakia issued a draft law to amend its minimum tax act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU Directive DAC 9 amendments. On December 23, 2023, Act No. 507/2023 to implement relevant provisions of the EU Minimum Tax Directive, was published in the Official Gazette. On September 11, 2024, the government of Slovakia approved a draft bill on amendments to the law to reflect various aspects of the OECD Administrative Guidance. This was approved by Parliament on November 28, 2024. On December 17, 2024, amendments to the DMTT legislation were published in the Official Gazette. |
| Effective Date | Accounting periods beginning on or after December 31, 2023 |
| IIR | No |
| UTPR | No |
| QDMTT | Yes (2024) |
| Filing Deadlines | Standard |
| Safe Harbours | Transitional CbCR Safe Harbour (the 2024 Amending Law includes the NMCE Simplified Calculations Safe Harbour) |
On June 16, 2025, Slovakia issued a draft law to amend its minimum tax act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU Directive DAC 9 amendments. The final draft law was issued on August 20, 2025. This was approved by Parliament on October 21, 2025.
On September 11, 2024, the government of Slovakia approved a draft bill on amendments to the law to reflect various aspects of the OECD Administrative Guidance. This was approved by Parliament on November 28, 2024 and published in the Official Gazette on December 17, 2024.
On December 23, 2023, Act No. 507/2023 to implement relevant provisions of the EU Minimum Tax Directive, was published in the Official Gazette.
On December 4, 2023, the Slovakian Government approved the ‘Draft Act on the Equalization Tax to ensure a minimum level of taxation for multinational enterprise groups and large national groups’. The draft law was passed by the Legislative Council on December 8, 2023.
Slovakia has made use of the derogation under Article 50(1) of the EU Minimum Tax Directive, which allows EU member states which have up to 12 in-scope UPEs in their jurisdiction to postpone the implementation of the income inclusion rule (IIR) and the under-taxed profits rule (UTPR) until up to December 31, 2029.
As such, the Law does not contain provisions for an IIR or UTPR, but does implement a domestic minimum tax (intended to be a Qualified Domestic Minimum Top-Up Tax) for accounting periods beginning on or after December 31, 2023.
GLOBE APPLICATION
General
Whilst the Law is based on relevant provisions in the GloBE rules/EU Minimum Tax Directive, as the IIR and UTPR are not being implemented, numerous aspects are not included because they either relate to the IIR/UTPR or they are not relevant to Slovakia’s domestic tax regime. A number of aspects are, however, included in the November 2024 Amending Law.
For instance, the Law did not include relevant GloBE provisions for:
-Partially-owned parent entities (included in the November 2024 Amending Law)
-Intermediate parent entities (included in the November 2024 Amending Law)
-IIR/UTPR
-Refundable tax credits (included in the November 2024 Amending Law)
-Deemed distribution tax systems
-Ultimate parent entities subject to a deductible dividend regime (included in the November 2024 Amending Law)
-The stock-based compensation election (included in the November 2024 Amending Law)
-The consolidation election (included in the November 2024 Amending Law)
-The GloBE loss election (included in the November 2024 Amending Law)
The amendments in the November 2024 Amending Law apply as from December 31, 2024.
Administrative Guidance
Aspects of the OECD Administrative Guidance included in the Law and the November 2024 Amending Law are:
-Currency Conversion Rules (Article 1.1)
-Sovereign wealth funds and the definition of Ultimate Parent Entity (Article 1.4 – included in the November 2024 Amending Law)
-Meaning of “ancillary” for Non-Profit Organisations (Article 1.6 – included in the November 2024 Amending Law)
-Forex hedge election (Article 2.2 – included in the November 2024 Amending Law)
-Debt release election (Article 2.4 – included in the November 2024 Amending Law)
-Excess Negative Tax Carry-forward Guidance (Article 2.7)
-Substitute Loss carry forwards (Article 2.8 – included in the November 2024 Amending Law)
-Equity Gain or loss inclusion election (Article 2.9 – included in the November 2024 Amending Law)
-The Extension of the Taxable Distribution Method Election to Insurance Investment Entities (Article 3.1)
-Exclusion of Insurance Investment Entities from the definition of Intermediate Parent Entity and Partially-Owned Parent Entity (Article 3.2 – included in the November 2024 Amending Law)
-Liabilities related to Excluded Dividends and Excluded Equity Gain or Loss from securities held on behalf of policyholders (Article 3.4 – included in the November 2024 Amending Law)
-Portfolio Shareholding Election (Article 3.5)
-Application of the Tax Transparency Election to Mutual insurance companies (Article 3.6 – included in the November 2024 Amending Law)
-Transitional rules (Article 4 – included in the November 2024 Amending Law)
-Marketable Transferable Tax credits (Article 2 of the Second Set of OECD Administrative Guidance – included in the November 2024 Amending Law)
-Additional rules (such as the deemed 50% requirement where employees perform work outside the employer’s jurisdiction for the SBIE – included in the November 2024 Amending Law).
Aspects of the June 2024 and January 2025 OECD Administrative Guidance included in the October 2025 Amending Law are:
-Article 1.2.1 – Aggregate DTL Category basis
-Article 1.2.1 – Exclusion of certain types of general ledger (GL) accounts and separate tracking
-Article 1.2.1 – Exclusion of GL accounts that generate standalone DTAs
-Article 1.2.1 – Exclusion of swinging accounts and separate tracking
-Article 1.2.2 – FIFO/LIFO basis
-Article 1.2.2 – Aggregation of Short-term DTLs
-Article 1.2.2 – Reversal of DTLs that accrued before the Transition Year
-Article 1.2.2 – 5-year unclaimed accrual election
-Article 2.1.2- Recalculated deferred tax where GloBE carrying value differs from accounting carrying value
-Article 3.1.3 – General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps (subject to a Ministry of Finance Regulation)
– Article 3.1.3- Specific rules for foreign PEs/CFCs, Hybrids/reverse hybrids with domestic source income (subject to a Ministry of Finance Regulation)
-Article 3.1.3- Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries (subject to a Ministry of Finance Regulation)
– Article 4.2 – Allocation of deferred tax expenses and benefits from a Parent Entity to a CFC, PE, Hybrid or Reverse Hybrid: 5 step process (subject to a Ministry of Finance Regulation)
– Article 4.2.2 – Five-Year Election to exclude the allocation of all deferred tax expenses and benefits to CFCs, PEs, Hybrids and Reverse Hybrids
-Article 5.2.2 – Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity
-Article 5.2.2 – Non-group owners: Partially owned Flow-through Entities
-Article 5.3.5 – Non-group owners: Indirect minority ownership
-Article 5.4.2 – Taxes allocated to a flow through entity
-Article 5.5.2 – Hybrid entities – Taxes pushed down include indirect owners
-Article 5.5.4 – Hybrid entities – Entities located in jurisdictions without a Corporate Income Tax system
-Article 5.6.2 – Extension of taxes pushed down to include Reverse Hybrids
-Article 9.1.1 from the January 2025 OECD Administrative Guidance.
Safe Harbours
Section 32 of the Law provides for the Transitional CbCR Safe Harbour. This is based on the OECDs Safe Harbour and Penalty Relief guidance.
The November 2024 Amending Law includes amendments for Purchase Accounting Adjustments (consistent reporting condition, goodwill impairment adjustment) and hybrid arbitrage arrangements, as provided in the December 2023 OECD Administrative Guidance.
The Explanatory Notes to the amending law also state that the other amendments to the Transitional CbCR as provided in that Administrative Guidance will also apply, eg:
-Transitional CbCR – JVs
-Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting
-Transitional CbCR – Using different accounting standards
-Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches
-Transitional CbCR – MNEs not required to file CbC Reports
-Transitional CbCR – Qualified Financial Statements for PEs
-Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities
Article 1(42) of the November 2024 Amending Law also includes the NMCE Simplified Calculations Safe Harbour.
The October 2025 Amending Law includes amendments to the Transitional CbCR Safe Harbour to reflect the January 2025 OECD Administrative Guidance to exclude specified reversals from the definition of simplified covered taxes.
ELECTIONS
Elections in the OECD Model Rules
The elections included in the OECD Model Rules and the EU Minimum Tax Directive that are provided in the Law, are:
-Excluded Entity Election (Section 3(4) of the Law)
-Election to use the Realization Method (Section 8 of the Law)
-Election to Spread Capital Gains (Section 9 of the Law)
-Unclaimed Accrual Election (Section 18(1) of the Law)
-Prior Year Adjustment Election (Section 20(3) of the Law)
-De minimis Election (Section 31 of the Law)
-Substance-Based Income Exclusion Election (Section 23(2) of the Law)
-Taxable Distribution Election (Section 30 of the Law)
-Tax Transparency Election (Section 29 of the Law)
The November 2024 Amending Law includes the Stock-based Compensation election, GloBE loss election and the Consolidation election.
Elections in the Administrative Guidance
The elections from the OECD Administrative Guidance included in the Law/November 2024 Amending Law are the:
-Portfolio Shareholding Election (Section 6(3) of the Law);
-Excess Negative Tax Carry-Forward Election (Section 17(4) of the Law);
-Equity Investment Inclusion Election (Section 1(14) of the Amending Law);
-Debt Release Election (Section 1(14) of the Amending Law); and the
-Foreign Exchange Hedge Election (Section 1(13) of the Amending Law);.
New Elections
None.
DEVIATIONS FROM THE OECD MODEL RULES/EU GLOBAL MINIMUM TAX DIRECTIVE
As Slovakia is postponing the implementation of the IIR and UTPR and only implementing a QDMTT, certain aspects of the Model GloBE rules are not included in the Law. This is because they are either not relevant to a QDMTT or they do not relate to Slovakia’s domestic tax regime (for instance, there is no deemed distribution tax regime election).
The 2024 Amendment Law included numerous aspects of the OECD Administrative Guidance, however, these apply from December 31, 2024. For example, the change to the accounting standard rule to eliminate the use of a local accounting standard (see Section 6.2) applies to accounting periods beginning on or after December 31, 2024. As such entities within the scope of the Slovakian QDMTT from December 31, 2023 to December 30, 2024 apply the previous provisions.
DOMESTIC MINIMUM TAX
General
Section 3(1) of the Law provides that Slovakia will apply a domestic minimum top-up tax (intended to be a QDMTT) for financial years beginning on or after December 31, 2023.
QDMTT Design Features
The QDMTT applies to both MNE groups and domestic groups.
Most other jurisdictions that are implementing the IIR and UTPR, provide that the standard GloBE calculation rules apply for determining the top-up tax, but they are then subject to a number of adjustments. As Slovakia is postponing the IIR/UTPR implementation, the Law is only providing for the calculation of the Top-Up Tax under the QDMTT.
100% of the Top-Up Tax
Section 3(1) of the Law provides that Top-up Tax that is subject to the QDMTT is based on the whole amount of the Jurisdictional Top-up Tax calculated, irrespective of the Ownership Interests held in the Constituent Entities located in Slovakia by any Parent Entity.
Jurisdictions may design their QDMTT legislation to apply only where all the domestic Constituent Entities in the jurisdiction are 100% owned by the UPE or a POPE for the entire Fiscal Year, but this is not the approach Slovakia has taken.
Accounting Standards/Currency
Section 5 of the Law provides specific rules as to when a local accounting standard can be used.
It provides that for the purposes of determining profits of Slovakian group entities, it is permitted to use either the:
-accounting standard used in the preparation of the consolidated financial statements of the ultimate parent entity (before consolidation adjustments); or
-the local accounting standard when used by domestic constituent entities for the preparation of their financial accounts (under Act No 431/2002 Coll. on Accounting, as amended.)
Section 45(2) of the Law provides that where the UPEs accounting standard is used, the ETR and top-up tax is calculated in the reporting currency.
However, if the QDMTT is determined on the basis of the local financial accounting standard, then the ETR and top-up tax should be determined in euros.
The November 2024 Amending Law, amends Section 5 of the Law to provide that the domestic minimum tax is calculated using the financial accounting standard of the UPE, and, if that is not practicable, on the basis of an accepted accounting standard or an approved accounting standard, if:
-the constituent entity’s financial statements are prepared in accordance with that standard,
-the information contained in the financial statements is reliable; and
-permanent differences of more than EUR 1 million are conformed with the UPEs accounting standard.
It also amends Section 45(2) so that the ETR calculation and top-up tax calculation is made in the reporting currency.
QDMTT Unpaid
Any QDMTT that has not been paid within four years is usually taken into account for top-up tax purposes in the fifth year. This does not apply for the QDMTT calculation (just for tax under an IIR or UTPR). This is required to avoid circularity and ensure the QDMTT is not taken into account for the domestic minimum tax calculation.
Push-Down Taxes
Tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules must be excluded, as provided in the OECD Administrative Guidance. This is included in Section 17(7) of the Law.
This preserves Slovakia’s primary right to tax income accruing to a Slovakian member entity which is also a CFC. If there were no statutory derogation from the general GloBE rules for the calculation of the domestic minimum tax, and the CFC tax paid by the controlling company abroad were included in the included taxes of the Slovakian CFC, the effective tax rate would be increased. Therefore, excluding the CFC tax from the Slovakian CFCs covered taxes allows Slovakia to tax low-taxed income at a higher rate than would be the case under an IIR.
Section 17(7) also prevents the pushdown of tax to hybrids, PEs and for taxes on distributions (except for Slovakian withholding tax on dividends) as is required under the OECD Administrative Guidance.
The October 2025 Amending Law will also apply the above approach to a reverse hybrid entity. In addition, an exemption is introduced for income tax collected from the owner of a hybrid entity or a reverse hybrid entity on income from sources in Slovakia under the Income Tax Act.
Exclusions
The Law does not apply the exemption for MNEs in their initial phase of international activity, for QDMTT purposes.
Transition Year
Article 1,51 of the November 2024 Amending Law provides for the transitional year refreshing rule.
A new transition year, arises in an accounting period in which the entities of an MNE/domestic fall within the scope of a qualified IIR or UTPR if this accounting period begins after the beginning of the transition year for QDMTT purposes.
In the new transition year the following attributes of the relevant Constituent Entities are refreshed:
-Any Excess Negative Tax Expense Carry-forward under Article 4.1.5 or Article 5.2.1 is eliminated at the beginning of the new Transition Year.
-The DTL recapture rule in Article 4.4.4 does not apply to any deferred tax liability that was taken into account in computing the ETR under the QDMTT and that was not recaptured prior to the new Transition Year.
-Any GloBE Loss Deferred Tax Asset that arose in a year preceding the new Transition Year must be eliminated. The Filing Constituent Entity may make a new GloBE Loss election in the new Transition Year.
-The deferred tax items previously determined are eliminated and Article 9.1.1 is applied at the beginning of the new Transition Year.
-Article 9.1.2 applies to transactions occurring after November 30, 2021 and before the beginning of the new Transition Year. However, if QDMTT was payable due to the application of Article 4.1.5 in respect of a deferred tax asset attributable to a tax loss, the deferred tax asset is not treated as arising from items excluded from the computation of GloBE Income or Loss under Chapter 3 of the OECD Model Rules.
Registration
Not provided in the Law.
Filing
Section 39 of the Law requires the submission of an Information Return.
The proposed approach is that every Constituent Entity located in Slovakia will have an obligation to file an information return in Slovakia. However, this obligation can be discharged if the information return is filed by:
– The Ultimate Parent Entity, or
– The Designated Filing Entity.
Where the information return is being filed by either the Ultimate Parent Entity or the Designated Filing Entity, the Constituent Entity, must file a notification with the Revenue.
The notification must contain:
– Details of the entity that is filing the information return, and
– The jurisdiction in which such an entity is located.
Where the information return is filed by the Designated Local Entity it needs to outline the Constituent Entities that it is filing on behalf of.
Both the information return and associated notifications must be filed no later than 15 months after the end of the fiscal year (with an 18-month deadline for the Transition Year).
Under Section 39(7) of the Law, the UPE of a multinational enterprise group located in Slovakia is required to designate a designated filing entity located in another Member State of the European Union (or, if the multinational enterprise group does not have a parent entity in another Member State of the European Union, in a State with which Slovakia has a qualified competent authority agreement in force), and must provide it with the information necessary for the calculation of the top-up tax for the multinational enterprise group.
Section 40 of the Law also requires the submission of a top-up tax return within 15 months after the end of the relevant tax period. If the tax period is a transitional year, the filing deadline is 18 months. No extension or waiver to the filing deadline is permitted. The top-up tax return must be submitted electronically.
Part II of the October 2025 Amending Law implements the EU DAC 9 amendments. This simplifies reporting in-scope groups by enabling central filing of a top-up tax information return (TTIR) and introduces a standard form for filing the TTIR across the EU, in line with the GIR.
Payment
Section 40(2) of the Law requires payment of top-up tax by the filing deadline.
Penalties
Section 43 of the Law provides that a penalty of between EUR 1,500 and EUR 50,000 applies for failure to file or late filing of the information return or top-up tax return.
On November 18, 2025, Slovakia issued its QDMTT Return along with completion instructions.
| Slovakia | |||
|---|---|---|---|
| Effective Date: | Accounting periods beginning on or after December 31, 2023 | ||
| Section/Article | |||
| First Set of OECD Administrative Guidance | |||
| 1.1 | Rebasing monetary thresholds in the GloBE Rules | 45 | |
| 1.2 | Deemed consolidation test | – | |
| 1.3 | Consolidated deferred tax amounts | amending law, Art 1,1 exclude state entities | |
| 1.4 | Sovereign wealth funds and the definition of Ultimate Parent Entity | Amending law, Art 1,8 | |
| 1.5 | Clarifying the definition of ‘Excluded Entity’ | – | |
| 1.6 | Meaning of ancillary for Non-Profit Organisations | Amending law, Art 1,8 | |
| 2.1 | Intra-group transactions accounted at cost | – | |
| 2.2 | Excluded Equity Gains or Loss and hedges of investments in foreign operations | Amending law, Art 1,13 | |
| 2.3 | Excluded Dividends- Asymmetric treatment of dividends and distributions | Amending law, Art 1,12 | |
| 2.4 | Debt release Election | Amending law, Art 1,14 | |
| 2.5 | Accrued Pension Expenses | Amending law, Art.1.11 | |
| 2.6 | Covered Taxes on deemed distributions | – | |
| 2.7 | Excess Negative Tax Carry-forward guidance | 17(3) | |
| 2.8 | Substitute Loss carry forwards | Amending law, Art 1,22 | |
| 2.9 | Equity Gain or loss inclusion election | Amending law, Art 1,14 | |
| 2.9 | Qualified Ownership Interest/Flow through entity | Amending law, Art 1,14 | |
| 2.1 | Allocation of taxes arising under a Blended CFC Tax Regimes | – | |
| 3.1 | Application of Taxable Distribution Method Election to Insurance Investment Entities | 30(1) | |
| 3.2 | Exclusion of Insurance Investment Entities from the definition of Intermediate Parent Entity and Partially-Owned Parent Entity | Amending law, Art 1,6 | |
| 3.3 | Restricted Tier 1 Capital | – | |
| 3.4 | Liabilities related to Excluded Dividends and Excluded Equity Gain or Loss from securities held on behalf of policyholders | Amending law, Art 1,17 | |
| 3.5 | Simplification for Short-term Portfolio Shareholdings | 6(3) | |
| 3.6 | Application of Tax transparency election to Mutual insurance companies | Amending law, Art 1.33 | |
| 4.1 | Deferred tax assets with respect to tax credits under Article 9.1.1 | Amending law, Art 1,50 | |
| 4.2 | Applicability of Article 9.1.3 to transactions similar to asset transfers | Amending law, Art 1,50 | |
| 4.3 | Asset carrying value and deferred taxes under 9.1.3 | Amending law, Art 1,50 | |
| Second Set of OECD Administrative Guidance | – | ||
| 1 | Currency conversion rules | 45 (Partial) | |
| 2 | MTTCs | Amending law, Art 1,6/9 | |
| 3 | SBIE Rules | – | |
| – Foreign rules | Amending law, Art 1,29 | ||
| Stock-based compensation election | – | ||
| Leases | Amending law, Art 1,29 | ||
| – Impairment losses inc in tangible asset value | – | ||
| 4.1 | QDMTT Safe Harbour | – | |
| 4.2 | UTPR Safe Harbour | – | |
| Third Set of OECD Administrative Guidance | |||
| 1 | Transitional CbCR – Purchase Accounting Adjustments (consistent reporting condition, goodwill impairment adjustment) | Amending law, Art 1,40 | |
| 2.2.1 | Transitional CbCR – JVs | Explanatory Notes | |
| 2.3.1 | Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting | Explanatory Notes | |
| 2.3.2 | Transitional CbCR – Using different accounting standards | Explanatory Notes | |
| 2.3.3 | Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches | Explanatory Notes | |
| 2.3.4 | Transitional CbCR – MNEs not required to file CbC Reports | Explanatory Notes | |
| 2.3.5 | Transitional CbCR – Qualified Financial Statements for PEs | Explanatory Notes | |
| 2.4.2 | Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities | Explanatory Notes | |
| 2.6 | Transitional CbCR – Treatment of hybrid arbitrage arrangements | Amending law, Art 1,45 | |
| 3.1 | Identifying Consolidated Revenue | ||
| 3.2 | Mismatch between Fiscal Years of the UPE and another Constituent Entity | ||
| 3.3 | Mismatch between Fiscal Year and Tax Year of Constituent Entity | ||
| 4.2.1 | Blended CFCs -multiple GloBE Jurisdictional ETRs | ||
| 4.2.2 | Blended CFCs – not required to calculate an ETR | ||
| 4.2.3 | Blended CFCs – income of non-GloBE Entities | ||
| 5.3 | 30 June 2026 Filing deadline | Amending law, Art 1,53 | |
| 6 | NMCE Simplified Calcs | Amending law, Art 1,45 | |
| Fourth Set of OECD Administrative Guidance | |||
| 1.2.1 | Aggregate DTL Category basis | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | |
| 1.2.1 | Exclusion of certain types of GL accounts and separate tracking | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | |
| 1.2.1 | Exclusion of GL accounts that generate standalone DTAs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | |
| 1.2.1 | Exclusion of swinging accounts and separate tracking | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | |
| 1.2.2 | FIFO/LIFO Basis | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | |
| 1.2.3 | Aggregation of Short-term DTLs | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | |
| 1.2.2 | Reversal of DTLs that accrued before the Transition Year | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | |
| 1.2.2 | 5 year unclaimed accrual election | October 2025 Amendment Law – Section 18, paragraph 1, letter b), Section 18, paragraphs 10 to 15 and Section 18b | |
| 2.1.2 | Recalculated deferred tax where GloBE carrying value differs from accounting carrying value | October 2025 Amendment Law – Section 18, paragraph 16 | |
| 2.1.2 | GloBE and accounting carrying values and the Transition Rules | ||
| 2.1.2 | Additional provisions for Intragroup transactions accounted for at cost | ||
| 2.1.2 | Exclusion of GloBE carrying value from SBIE | ||
| 3.1.3 | General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps | October 2025 Amendment Law- 19(10) – subject to MoF Regulation | |
| 3.1.3 | Specific rules for foreign PEs/CFCs, Hybrids/rev hybrids with domestic source income | October 2025 Amendment Law- 19(10) – subject to MoF Regulation | |
| 3.1.3 | Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries | October 2025 Amendment Law- 19(10) – subject to MoF Regulation | |
| 4.1 | Extension of the Substitute Loss Carry-forward DTA to PEs, hybrids and rev hybrids | ||
| 4.2 | Allocation of deferred tax expenses and benefits from a Parent Entity to a CFC, PE Hybrid or Rev Hybrid: 5 step process | October 2025 Amendment Law- 19(10) – subject to MoF Regulation | |
| 4.2.2 | Five-Year Election to exclude the allocation of all deferred tax expenses and benefits to CFCs, PEs, Hybrids and Rev Hybrids | October 2025 Amendment Law- 19(11) | |
| 4.2.3 | Exclusion of deferred tax assets or liabilities arising under a Blended CFC regime from transition rules | ||
| 5.2.2 | Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity | October 2025 Amendment Law- § 2 letter and ab ), § 2 letter and ac ), § 2 letter bs ) and § 14 par. 4 | |
| 5.3.2 | Non-group owners: Partially owned Flow-through Entities | October 2025 Amendment Law- § 14 par. 1 letter b) | |
| 5.3.5 | Non-group owners: Indirect minority ownership | October 2025 Amendment Law – § 14 par. 1 letter b) | |
| 5.4.2 | Taxes allocated to a flow-through entity | October 2025 Amendment Law – § 2 letter and ab ), § 2 letter and ac ), § 2 letter bs ) and § 14 par. 4 | |
| 5.5.2 | Hybrid entities – Taxes pushed down include indirect owners | October 2025 Amendment Law – § 2 letter and ab ), § 2 letter and ac ), § 2 letter bs ) and § 14 par. 5 | |
| 5.5.4 | Hybrid entities – Entities located in jurisdictions without a Corporate Income Tax system | October 2025 Amendment Law- § 2 letter and ab ), § 2 letter and ac ), § 2 letter bs ) and § 14 par. 6 | |
| 5.6.2 | Extension of taxes pushed down to include Reverse Hybrids | October 2025 Amendment Law – § 17 paragraph 7 and § 19 paragraph 4 | |
| 6.1.4 | Option to exclude a Securitization Entity from scope of QDMTT | ||
| 6.1.4 | Option to not impose top-up tax liabilities on SPVs used in securitization transactions | ||
| 6.1.4 | Amendments to the Switch-Off rule | ||
| 6.1.4 | New definition: Securitization Entity | ||
| 6.1.4 | New definition: Securitization Arrangement | ||
| January 2025 OECD Administrtive Guidance | |||
| 1 | Articles 8.1.4 and 8.1.5 | ||
| 1 | Amendments to CbCR Safe Harbour for 9.1 | October 2025 Amendment Law – § 32 par. 10 to 12 and § 46b | |
| 1 | Amendments to QDMTT Safe Harbour for 9.1 | ||
| 1 | Article 9.1 of the GloBE Rules | October 2025 Amendment Law – § 32 par. 10 to 12 and § 46b | |
| 1 | Central Record of Legislation with Transitional Qualified Status |
| Note | Slovakia | |
|---|---|---|
| QDMTT?(Enacted/Draft) | Is there a QDMTT in the Legislation? | Yes – Enacted |
| Effective Date: | Accounting periods beginning on or after December 31, 2023 | |
| Administrative Guidance/Safe Harbour Guidance? | Are the provisions of the OECD Administrative Guidance and Safe Harbour Guidance reflected in the current legislation? | Partially |
| Separate/Transposed QDMTT | Is the QDMTT a Separate QDMTT or a Transposition of the GloBE Rules (with Amendments) | Separate |
| Domestic Groups | A QDMTT can also apply to purely domestic groups. | Yes – Section 1 |
| Scope Definitions | The definitions of Ultimate Parent Entity, MNE Group, and Constituent Entity correspond with the definitions in the GloBE Rules. | Yes – Section 2 |
| Income and covered taxes of Constituent Entities | The QDMTT must compute the tax liability for the jurisdiction by taking into account the income and covered taxes of Constituent Entities under the GloBE Rules. | Yes – Section 6 |
| Separate ETRs | A QDMTT must determine a separate ETR and Top-up Tax amount for MOCEs, Joint Ventures and JV Subsidiaries. | Yes – Section 26 |
| Charging | A QDMTT must impose a Top-up Tax on one or more domestic Constituent Entities on the Excess Profits of all domestic Constituent Entities, including the domestic Parent Entity. | Yes – Section 122 |
| Enforceability | The legal liability for the domestic top-up tax needs to be enforceable against at least one Constituent Entity in the jurisdiction. | Yes – Section 37 |
| Different Accounting Standard? – Optional | Is the use of a local accounting standard optional? | Section 5 (as amended in the November 2024 amending law) applies the standard GloBE rules – see our GloBE Country Guide) |
| Different Accounting Standard? – Mandatory | Is the AG2 guidance followed? | No |
| Different Accounting Standard? – Default GloBE rules | Do the general GloBE rules apply for the QDMTT accounting standard? | No |
| Require 100% ownership? | The QDMTT )can require 100% ownership | No |
| Differences to GloBE Rules: tighter restriction is consistent with local tax rules | The QDMTT can be more restrictive than the GloBE Rules where the tighter restriction is consistent with local tax rules. | None aside from below |
| Differences to GloBE Rules: Not relevant to in the context of its domestic tax system | The QDMTT can exclude adjustments that are not relevant to in the context of its domestic tax system. | Yes – numerous ( eg no distribution tax regime election). See our GloBE Guide |
| Income/Loss of a PE | The QDMTT must exclude the income or loss of a foreign Permanent Establishment from the income or loss of the Main Entity. | Yes – Section 13 |
| Tax Transparency | A QDMTT must include certain tax transparent provisions. | Yes – Section 14/15 |
| Adjusted Covered Taxes Consistency | The range of taxes included in Covered Taxes needs to be the same or narrower, as under the GloBE rules. | Yes – Section 2(ak) |
| GloBE Loss Election? | Not Required in QDMTT | No (included in the November 2024 amending law) |
| No Pushdown to CFC or PE | A QDMTT must exclude: (1) tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules and (2) tax paid or incurred by a Main Entity that is allocated to a PE in the jurisdiction. | Yes – Section 17(7) |
| Exclude tax allocated to Hybrids | Second AG Guidance | Yes – Section 17(7) |
| Exclude allocated net basis tax on dividends (except WHT) | Second AG Guidance | Yes – Section 17(7) |
| UPE that is a Flow-Through Entity | Second AG Guidance | Yes – Section 15 |
| UPE subject to Deductible Dividend Regime | Second AG Guidance | No (included in the November 2024 amending law) |
| Eligible Distribution Tax Systems | Second AG Guidance | No |
| ETR Computation for Investment Entities | Second AG Guidance | Yes – Section 28 |
| Investment Entity Tax Transparency Election | Second AG Guidance | Yes – Section 29 |
| Taxable Distribution Method Election | Second AG Guidance | Yes – Section 30 |
| Multi-Parented MNE Groups | Second AG Guidance | Yes – Section 27 |
| Additional Top-Up Tax/Excess Negative Tax Expense | A QDMTT needs to have provisions for additional top-up tax where there is no Net GloBE Income and the Adjusted Covered are less than zero and less than the Expected Adjusted Covered Taxes. Amount. Excess Negative Tax Carry-forward rules also need to be in place. | Yes – Section 17/24 |
| Modified Top-Up Tax Formula | The QDMTT top-up tax formula needs to be modified as the GloBE Rules subtract tax paid under a QDMTT from the current GloBE Top-up Tax. | N/A as no IIR/UTPE |
| Same Approach As GloBE Rules | A QDMTT must require that top-up tax is taken into account by the relevant Constituent Entity at the same time and in the same manner as under the GloBE Rules (eg it can’t be carried forward). | Yes |
| SBIE Included? | Not Required in QDMTT | Yes – Section 23 |
| SBIE Rates same as GloBE? | Not Required in QDMTT | Yes – Annex 1 |
| De Minimis Rule Included? | Not Required in QDMTT | Yes – Section 31 |
| Restructuring Rules? | A QDMTT needs to include restructuring rules as provided in the GloBE rules to the extent necessary to conform to the tax reorganization rules in the jurisdiction. | Yes – Section 34/35 |
| Safe Harbours? | A QDMTT needs to contain GloBE safe harbours. | Yes – Section 32 |
| Deferred Tax Transition Rule? | A QDMTT must include the deferred tax starting point under Article 9.1.1 of the Model Rules. | Yes – Part 7 |
| SBIE Transitional Rates? | Not Required in QDMTT | Yes |
| Initial Phase of International Activity Exemption | Not Required in QDMTT | No |
| Elections? | Where the GloBE Rules permit an election, a QDMTT must generally also provide for the election and require the MNE Group to make the same election under the QDMTT as is made under the GloBE Rules. | Yes but elections are limited. see our GloBE Guide. |
| Deferred Tax transition: First time or refreshing rule? | Second AG | None (included in the September draft law) |
| New transition year – amend tax attributes? | Second AG | Yes (included in the November 2024 amendment law) |
| Currency provisions? | Second AG | Partially (the reporting currency is to be used if the UPE accounting standard is used. If the Slovak accounting standard is used, Euros are to be used for the ETR/Top-Up Tax Calculation). The November 2024 amending law provides the reporting currency is to be used. |
| DTL Recapture rules – Aggregate DTL Categories | Fourth AG, 1.2.8 | Yes (included in the October 2025 amendment law) |
| DTL Recapture rules Unclaimed Accrual Five-Year Election | Fourth AG, 1.2.8 | Yes (included in the October 2025 amendment law) |
| Reverse Hybrid Pushdown | Fourth AG, 5.6.2 | Yes (included in the October 2025 amendment law) |
| Securitization Entities – A QDMTT may also exclude a Securitisation Entity from its scope | Fourth AG, 6.1.4 | |
| Securitization Entities – A jurisdiction may allocate the QDMTT liability for any QDMTT top-up tax to another Constituent Entity (if any) that is located in the jurisdiction | Fourth AG, 6.1.4 | |
| Note |
| Slovakia | ||
|---|---|---|
| Effective Date: | Accounting periods beginning on or after December 31, 2023 | |
| Section/Article | ||
| Safe Harbour & Penalty Relief Guidance | De Minimis Test | 32(2) |
| Safe Harbour & Penalty Relief Guidance | Simplified ETR Test | 32(2) |
| Safe Harbour & Penalty Relief Guidance | Routine Profits Test | 32(2) |
| Safe Harbour & Penalty Relief Guidance | Simplified Covered Tax defn (inc exclusion of uncertain tax positions) | 32(1)(e) |
| Safe Harbour & Penalty Relief Guidance | Simplified ETR defn | 32(1)(c) |
| Safe Harbour & Penalty Relief Guidance | Transition Period | 32(1)(f) |
| Safe Harbour & Penalty Relief Guidance | Transition Rate | 32(1)(f) |
| Safe Harbour & Penalty Relief Guidance | Defn of Qualified Financial Statements | 32(1)(b) |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Joint Ventures | 32(3) |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Tax Neutral UPEs | 32(4) |
| Safe Harbour & Penalty Relief Guidance | Special Rules for Investment Entities and their Constituent Entity-owners | 32(5) |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Net Unrealised Fair Value Loss | 32(1) |
| Safe Harbour & Penalty Relief Guidance | Exclusions | 32(7) |
| December 2023 OECD Administrative Guidance | ||
| 1 | Transitional CbCR – Purchase Accounting Adjustments(consistent reporting condition, goodwill impairment adjustment) | Amending law, Art 1,40 |
| 2.2.1 | Transitional CbCR – JVs | Explanatory Notes |
| 2.3.1 | Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting | Explanatory Notes |
| 2.3.2 | Transitional CbCR – Using different accounting standards | Explanatory Notes |
| 2.3.3 | Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches | Explanatory Notes |
| 2.3.4 | Transitional CbCR – MNEs not required to file CbC Reports | Explanatory Notes |
| 2.3.5 | Transitional CbCR – Qualified Financial Statements for PEs | Explanatory Notes |
| 2.4.2 | Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities | Explanatory Notes |
| 2.6 | Transitional CbCR – Treatment of hybrid arbitrage arrangements | Amending law, Art 1,45 |
| January 2025 OECD Administrtive Guidance | ||
| Amendments to CbCR Safe Harbour for 9.1 | October 2025 Amending Law |
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